In brief
A chemical inventory is a list showing, for every chemical product in the workplace, its name, supplier, hazard statements, the date of its Turkish-language SDS, stock quantity, place of use and who is exposed. The Regulation on Health and Safety Measures in Work with Chemical Substances does not use the word "inventory", but all the information it requires in the risk assessment comes from this list. The inventory is built by walking the site, unused chemicals are weeded out, and it is updated with every new purchase.
What is a chemical inventory for?
In a plastic injection moulding workshop, the mould release spray, the maintenance team's rust remover, the water treatment chemical in the boiler room and the descaler in the cleaning cupboard are all in the same workplace but in different hands. A chemical inventory, the workplace's list of chemical substances, turns this scattered picture into a single list: it shows which chemicals are in the workplace, where, in what quantity, and who works with them.
The word "inventory" does not appear in the text of the Regulation on Health and Safety Measures in Work with Chemical Substances (Official Gazette 12.08.2013; last amended Official Gazette 20.10.2023). But Article 6 of the Regulation requires the following information to be taken into account in the risk assessment:
None of the information on this list can be collected reliably without an inventory. We explained the general framework of the Regulation in our article on the chemical substances regulation; here we focus on how to build the inventory.
Step 1: Walk the site; do not rely on the purchasing list
The first draft of an inventory is usually taken from purchasing records and ends up incomplete. Products received as samples, sprays bought by the maintenance team themselves and drums left over from years ago do not appear in these records. So build the list by walking the site, not at a desk. Visit these points one by one:
- Raw material and chemical store, open stock areas,
- Production lines and the daily containers at the lines,
- Maintenance workshop, compressor and boiler rooms, water treatment unit,
- Laboratory and quality control,
- Cleaning supply cupboards and the kitchen,
- Temporary hazardous waste storage area.
Do not forget teams coming in from outside: subcontractors coming for maintenance, painting or cleaning work may work with their own chemicals. Ask these companies for a list of the products they bring and their Turkish-language SDSs before work starts, and add them to the inventory temporarily.
At each point, note the container's label, quantity and type. When you find an unlabelled bottle or a drum with unknown contents, write it on a separate "unidentified" list; these containers are either identified or disposed of as hazardous waste.
Step 2: What columns make up a chemical inventory form?
A good chemical inventory form contains one row for each product and one column for each piece of information the risk assessment needs. Our suggested columns and the source of the information:
| Column | Source of information | Why is it needed? |
|---|---|---|
| Product trade name and supplier | Label, invoice | To identify the product and request the SDS |
| Hazardous components | SDS Section 3 | To see substances with limit values |
| Hazard pictograms and H statements | SDS Section 2, label | To see the product's hazard class |
| SDS language and revision date | First page of the SDS | To check for a current Turkish-language SDS |
| Physical state and flash point | SDS Section 9 | To assess fire and vapour risk |
| Incompatible materials | SDS Section 10 | To decide what is kept separate in the store |
| Personal protective equipment | SDS Section 8 | To build the PPE matrix |
| Storage location and maximum stock | Site observation | Fire load and spill scenario |
| Place of use, process and roles using it | Site observation, section supervisor | To see who is exposed |
| Monthly consumption | Purchasing, store issues | To estimate the frequency of exposure |
| Method of use | Site observation | Difference between spraying, open container and closed system |
| Responsible person | Section management | To take ownership of updates |
Keeping this form in a spreadsheet is enough. What matters is that the columns are filled in for every product and empty cells are marked as "unknown"; an empty cell means a hazard overlooked in the risk assessment.
Step 3: Check the date and language of the SDS
The Regulation requires the Turkish-language SDS obtained from the supplier to be taken into account in the risk assessment; the employer is obliged to obtain the necessary information from the supplier and other sources, and the supplier is obliged to provide information when requested (Art. 6/3 and Art. 9/3). In the inventory, answer these three questions for each product:
- Is there an SDS? If not, request it from the supplier. Make it an internal rule not to bring into use a product whose SDS has not arrived.
- Is it in Turkish? A data sheet in a foreign language is not information the worker can access.
- Is it current? An SDS with a very old revision date may not reflect the product's current formulation. Ask the supplier for the latest version and write the date in the inventory.
Workers' access to SDSs is also an information topic required by the Regulation (Art. 9). Number the SDSs in the same order as the inventory and keep them in a folder close to the point of use or in a shared digital folder.
Step 4: Weed out unused chemicals
When the inventory is built, unused chemicals turn up in almost every workplace: a product that was tried and abandoned, oil left over from an old machine, an adhesive past its expiry date. Art. 7 of the Regulation gives clear direction here: the quantity of chemicals in the workplace is kept to a minimum, and a less hazardous chemical is used instead of a hazardous one.
- Unused products: Dispose of them as hazardous waste through licensed companies.
- Several products doing the same job: Choose one instead of three different degreasers, preferably the one with milder hazard statements.
- Excess stock: Limit the daily stock in the production area to one shift's or one day's requirement; keep the rest in the store.
- Chemicals that may affect each other: Art. 7 requires contact between chemicals that may affect each other to be prevented. Do not keep acids and bases, or oxidisers and flammables, on the same shelf.
Step 5: Link the inventory to the risk assessment
The inventory is not a document in its own right but an input to the risk assessment. Each row should turn into a decision in the assessment:
| What you see in the inventory | What it means in the risk assessment |
|---|---|
| Carcinogenic or reprotoxic H statement | Substitution research first; notify the workplace physician for health surveillance |
| Low flash point and large stock | Fire and explosion assessment; explosion protection document if necessary |
| Volatile product used in open containers for long periods | Need for workplace measurement; we plan measurements with authorised laboratories |
| Incompatible substances in the same store | Changing the store layout |
| Large-volume liquid container | Spill scenario and spill kit |
| Marked increase in consumption | Reassessment of exposure |
For areas with flammable liquids and dusts, see our article on the explosion protection document; for situations requiring measurement, our article on workplaces requiring workplace measurements; and for choosing a spill kit based on the inventory, our article on chemical spill response.
Example: The SDS of a mould release spray carries an extremely flammable aerosol warning and recommends local ventilation in Section 8. The inventory shows that the product is used on three injection moulding machines, several times per shift. Two rows go into the risk assessment: control of ignition sources around the machines and exposure during spray use. As a measure, switching to a liquid product or extraction at the point of application is considered.
Step 6: Chemical tracking: keeping the inventory up to date
The inventory starts going out of date from day one. For chemical tracking, link updates to events:
- New product: Before ordering a new chemical, purchasing requests its SDS and obtains the OHS specialist's opinion.
- SDS revision: A new version from the supplier is entered in the inventory; if the hazard statements have changed, the risk assessment is reviewed.
- Change of use: When the product starts being used on another line or by a different method, the row is updated.
- Periodic review: At least once a year, walk the site again and compare it with the list. Enter the date in the OHS calendar tool.
For other risks specific to chemical and plastics businesses, see our chemicals and plastics sector page.
Frequently Asked Questions
Is a chemical inventory a legal requirement?
The Regulation does not use the word "inventory". However, it requires information such as the chemical's hazards, its Turkish-language SDS, quantity, conditions of use and exposure to be taken into account in the risk assessment. The inventory is the practical way of collecting this information in an orderly way; it also shows what the chemical rows in the risk assessment are based on.
What should be done with a chemical that has no SDS?
Request a Turkish-language SDS from the supplier; the supplier is obliged to provide information when requested. Do not bring the product into use until the SDS arrives. Chemicals whose contents are unknown and whose supplier cannot be found should be disposed of as hazardous waste.
How often is the inventory updated?
With every new product purchase, every SDS revision and whenever the place or method of use changes. In addition, we recommend verifying the list by walking the site at least once a year.
Are cleaning materials included in the inventory?
Yes. Products such as descalers, bleach and degreasers also have hazard statements and SDSs. Cleaning staff work with these products every day; if they are not in the inventory, mixing and exposure risks are overlooked.
A risk assessment that identifies and scores hazards on site, links each measure to an owner and a date, and has a clear renewal schedule.
Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.